What is a mock grant review and why do one before an RHTP audit?

Why it is worth doing now

• States must monitor subrecipients. Under the Uniform Guidance, pass-through entities monitor subrecipient activity, review financial and performance reports and follow up on audit findings (2 CFR 200.332; eCFR). CMS also makes states responsible for subrecipient compliance (CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov)).
• The money is conditional. CMS ties continuation funding to satisfactory progress and compliance, and can withhold or recover funds (CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov)).
• Reimbursement depends on paperwork. On reimbursement-based awards, costs you cannot document may not be paid (Oklahoma State Department of Health).
• Single Audit exposure. Entities spending $1 million or more in federal awards in a fiscal year generally need a Single Audit (2 CFR 200.501; eCFR).

What a mock grant review typically covers

1. Award terms: scope, budget, deadlines and reporting schedule in your subaward
2. Allowable costs: each charge mapped to an approved use and budget line
3. Caps and restrictions: provider payments, capital and administrative limits; no supplanting or duplicate billing (CMS)
4. Documentation trail: invoices, time and effort, procurement and approvals
5. Milestones and outcomes: evidence you did what you said, with baseline data
6. Reports: accuracy and timeliness of what you have already sent the state
7. Subcontractors and vendors: whether they meet flow-down terms
8. A findings list with priorities and a corrective action plan

When to do one

Good times are before your first reimbursement request, before a scheduled state monitoring visit, before your fiscal year-end audit, and before applying for or continuing Year 2 funding.

Common questions

Is a mock grant review the same as a Single Audit?

No. A Single Audit is a formal, required audit under 2 CFR 200 Subpart F. A mock grant review is a voluntary practice review that helps you prepare for state monitoring and audits.

Who should do a mock grant review?

Someone independent of the staff who manage the grant day to day, so the review spots what an outside monitor would.

How long does a mock grant review take?

It depends on the size and complexity of your award and how organized your records are. Ask for a scoped estimate.

Sources

1. CMS Notice of Funding Opportunity CMS-RHT-26-001 (via Grants.gov)
2. eCFR: 2 CFR Part 200 (Uniform Guidance), incl. 200.101(b)(1), 200.332, 200.339, 200.501
3. Oklahoma State Department of Health: RHTP Chronic Disease Management NOFO
4. CMS: RHT Program Provider Payments fact sheet

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HealthRoots.ai is independent and is not affiliated with or endorsed by CMS or any state agency. This page is general information, not legal advice; always confirm requirements in your own award documents and with your state RHTP office.